Advocacy

Interactive Ontario’s mandate to promote the growth of Ontario’s interactive digital media industry includes a strong focus on advocacy at all levels of government. We are constantly working to ensure that the unique needs of our sector are considered when policy decisions are made.

Our advocacy work is informed by feedback from our members and input from our Advocacy Committee. See below for more information on our advocacy efforts surrounding key issues and please note Action Alerts where we are requesting participation from IDM companies.

Ontario Interactive Digital Media Tax CreditIn the fall of 2014, the Ontario government announced a review of the Ontario Interactive Digital Media Tax Credit. During this process, Interactive Ontario took part in numerous meetings with the Ministry of Tourism, Culture and Sport; the Ministry of Finance, the Treasury Board and the Premier’s Office. We were pleased with the outcome in the next provincial budget, with the OIDTMC rate left unchanged and guidelines changed to reduce “outliers” accessing the credit for products outside of its intended use.

Concerns remained around some of the new guidelines, so Interactive Ontario continued to collaborate with the government on issues such as:

Ontario Culture StrategyInteractive Ontario submitted comments during the development of the Ontario government’s first Culture Strategy. Our submission can be viewed here.

Budget consultationsInteractive Ontario attends in-person budget consultations to help ensure that programs like the Interactive Digital Media Fund and others are sufficiently funded.

CAVCO – ‘Shown in Canada’ eligible platformsIn the spring of 2016, the Canadian Audio-Visual Certification Office issued a call for comments on proposed changes to eligible platforms for the ‘shown in Canada’ requirement. The changes were designed to allow audio-visual productions whose distribution is exclusively via online platforms (including through mobile video services) to be eligible for the Canadian Film and Video Production Tax Credit (CPTC), provided that the rights have flown through a Canadian distributor to the entity showing the production in Canada.

Interactive Ontario welcomed this as a first step towards much-needed improved funding for digital-first linear video content, but also said that the regulations should be further amended to allow producers of self-distributed content to access the tax credit. This would bring policy into line with new business models and viewing habits of consumers in the digital era, who no longer distinguish between CRTC-licensed and non-CRTC-licensed content providers. Read our full submission here.

Canada Media FundThere are no major changes anticipated for the 2017-18 fiscal year, other than a re-allocation of $2 Million within the Experimental Fund to fund linear web series. However, CMF is looking to shift more funds increasing from the Innovation Program to the Commercial Projects Pilot Program. We will be monitoring that shift and the response to C3P, to identify any possible negative consequences for IO members.

As well, the CMF is looking to make changes to the Convergent Fund over the coming years that will impact how convergent digital media will be funded. They are looking to phase out the Digital Media Factor Weight in the calculation of broadcaster envelopes and replace that incentive with added funding to a revamped Convergent Digital Media Incentive. IO will be talking to CMF staff over the next year to minimize any negative impact on convergent digital media producers.

Advocacy matters involving federal departments are submitted via the CIAIC. Learn more about those efforts below.

DigiCanConInteractive Ontario actively encouraged members to submit their thoughts on Canadian Heritage’s Canadian Content in a Digital World consultations. We gathered feedback and ideas through a variety of methods, including a Twitter chat and Advocacy Committee meetings, in order to contribute to the CIAIC’s submission.

Certified Independent Production FundsIn August 2016 the CRTC released a new framework for Certified Independent Production Funds (CIPFs) (CRTC 2016-343), implementing changes effective September 1, 2016. The Commission stated it would ‘maintain a 10% limit on funding that can be allocated to non-programming digital content’. Previously that 10% cap (which is 10% of the revenues that a fund receives from cable and satellite companies) was only for standalone digital media and there was no cap on digital media affiliated with television programming.

Digital-first linear video could still be funded as CIPFs are no longer required to demand a broadcast licence for eligibility but any media that incorporates interaction would have to fit within the 10% cap. Given that this new rule would devastate the mandate of the Bell Fund, Telus Fund and Quebecor Fund and prevent the Shaw Rocket Fund from having its digital fund, the Bell Fund made two requests to the CRTC, which the CRTC posted for comment. It requested a one-year transition period to give companies time to fully understand the ramifications of these changes, and the Bell Fund time to adjust its funding programs and guidelines. It also requested an increase in the 10% cap to a more reasonable level.

Interactive Ontario met with the CRTC to discuss the potential impact of these CIPF changes on Canada’s digital media industry and contributed to the CIAIC’s submission in support of the Bell Fund’s letter.

Despite the efforts of IO, the Canadian Interactive Alliance, our member companies and other industry stakeholders such as the CMPA (whose interventions are noted here and here), on July 17, 2017 the CRTC denied the request by the Bell Fund for an increase to the 10% cap that CIPFs may spend on funding for non-programming digital content. The decision summary reads:

The Commission approves a request by the Bell Fund for a transition period to adapt its guidelines to the Commission’s new policy framework for Certified Independent Production Funds. The Bell Fund will have until 17 July 2018 to make the necessary changes.

The Commission denies a request by the Bell Fund for an increase to the 10% cap on funding for non-programming digital content.

Interactive Ontario has submitted a letter to the CRTC expressing our disappointment with this decision, which can be read here.

We will provide updates on guideline changes to the Bell Fund as they are available.

Innovation AgendaThe Ministry of Innovation, Science and Economic Development issued a call for ideas regarding Canada’s Innovation Agenda. The CIAIC response included a number of ways the IDM sector can continue to help position Canada as a global leader in innovation. These included:

Reducing barriers to collaboration, within IDM and across sectors

Mechanisms to encouraging risk-taking, such as a tax credit claimed on an annual basis for labour expenditures on innovative products, regardless of the eventual completion or financial success of the project

Funding for companies engaged in the production of content that is awarded on an enterprise, rather than per-project, basis